2014, July 20 | Sunday 7:00 pm

by Peter Samuel


Chapter 2 is a pretty straight history of the development of Frederick and a useful cataloguing of the various architectural styles and their periods – written by Dale Dowling. Importantly it makes plain that the historic district as we know it evolved as a result of individual initiatives and personal tastes and choices made in an unregulated real estate market. There was very little attempt at central planning via land use zoning and building regulations – let alone the detailed design supervision exercised by the 21st century HPC – before the downtown historic district had pretty much reached its present form.

Hence the delightful diversity of buildings and the many idiosyncrasies that give historic Frederick most its liveliness, interest and charm.

An exception was the first attempt at central planning – ‘project housing’ in the northwest and southwest of the historic district in which government powers of eminent domain were used in the 1960s for ‘slum clearance’ – to raze whole blocks of historic housing and erect welfare walkups, which were soon a typical planners’ disaster.

Greenspace “the most threatened resource”


COMMENT: The chapter has an oddly shrill conclusion about “threats” to our green space. After no mention of the issue in the many earlier pages we suddenly get this: “Frederick’s open and green spaces… may be the most threatened historic resource in the (historic district.)”

If that’s the case why the Guidelines’ preoccupation with regulating tiny details of trim and windows and texture of materials in rehabilitation and new construction.

City government has full control over how much of lots are developed through its building permits and zoning powers, so if the historic district is “overbuilt” at the expense of greenspace it will be because City Government decided to allow that. The City controls density of development via the R8, R12 etc zoning overlays.

The City too runs parks and can always acquire unused land for new parks if they are needed. Actually there’s a lot of undeveloped and landlocked space in the middle of many blocks in the historic district. The lots are often far deeper than needed by their owners, and the backs are often underused and sometimes overgrown. A useful City initiative would be adding missing sections of alley to give rear access to currently landlocked lots, and tidying up and paving the many gravel alleys – in the course of which it should be possible to add some extra greenspace.

Street trees in Frederick have miserably small planter areas, and would grow better with more generous space around their trunks. We’d be much better off too in improving our historic heritage with a program to rid the streetfronts of overhead wires and utility poles by undergrounding or using the alleys for utilities. Rather than expressions of HPC paranoia over ‘development,’ we need the City to exercise initiative and upgrade the street, alley and park system already within its jurisdiction.

Instead unfortunately the Historic Commission focusses its work on the negatives – throwing up roadblocks to property owners who want to preserve, rehabilitate and contribute to the historic district.

E2ndFlagsIt reflects poorly on City officials that they would sign on to a piece of shrill paranoid nonsense about threatened greenspace and omit completely to discuss any positive measures the City might take to help better the historic district.



No comment



A. Approved materials for rehabilitation including additions. On a case-by-case basis the HPC may approve use of materials acceptable for new construction as discussed in Chapter 10.


Every effort must be made to retain and preserve original materials, thus helping to maintain the historic character of a property. Character-defining features should be repaired rather than replaced.

COMMENT: “Every effort” is an exquisitely elastic term. On the one hand property owners have a strong incentive in the absence of any government dictat to repair rather than replace, except when, over time, the cost of repair/repair/repair is greater than replacement. On the other hand the historic preservation regulators given that it costs them nothing have an incentive to take a hardline against replacement and to demand expensive and repeated repairs. Indirectly the Guidelines are saying property owners should be prepared to pay a price premium – to choose the repairs option over replacement when that is more expensive. Such a requirement for inefficient choices diminishes property values and real incomes.

1. Brickwork to match existing…


2. A. Concrete, historic formed or block “shall be repaired and preserved.”119RecordLkgSth

QUESTION: Is formed and concrete block really historic? Here we have the extreme preservationism of wanting to keep something merely because it’s there, not because it is valuable or beautiful and deserves preservation on that account.

B. “Cast stone on sills, lintels and cornices and other architectural details shall be retained and preserved. If the Commission believes replacement of any feature is necessary, the replacement shall match the existing in material, size, form, color, texture and finish.”

3. Stone – historic details to be retained and preserved, no concealment by parging.

Historic garden walls and retaining walls to be retained and preserved unless they are determined to be beyond repair.

COMMENT: If someone wants to remove the walls, then they will be allowed to do so if they wait, and allow them to deteriorate to the “beyond repair” condition. Incentive to neglect is built into the Guidelines approach to regulate in the name of ‘preservation’ – regardless of the actual result.


Existing stucco and parging to be repaired and preserved if HPC rules it is original or removal will damage wall under. No new stucco on top of brick or stone or concrete block except on structures deemed non-contributing.

Promo for NPS preservation briefs.


C. Masonry treatments

more on character-defining features which should be repaired, not replaced.

AlwaysAdaptingIf missing their replacement should be compatible with the scale, size and material and color of the building, but be a contemporary design. Recreating an original feature without adequate documentation “would create a false sense of history and will not be approved.”


Painting of unpainted masonry “will not be approved” unless needed to stabilizing deteriorating brickwork. Same principles apply to stucco and parging.

Removal of paint from brickwork not allowed if removal will damage the brickwork.

Details on how to clean masonry – no sandblasting or strong chemicals or high-pressure (>300psi) water.

p48, 49

repointing and mortars, need for lime-sand mortars, little or no portland cement permitted

COMMENT: many different mortars including full portland cement mixes are in evidence around the historic district suggesting these HPC requirements are widely disregarded. We don’t see evidence that the harder mortars are damaging. It would be aesthetically more pleasing if the colors matched better, but there seems little enforcement here.



Once again the familiar “every effort” as judged by HPC “must be made to retain and preserve original materials” and “character-defining elements should be repaired rather than replaced.”CompositeLumb

1. Acceptable wood. “Any species of untreated, non-composite wood can be used for wood elements in the Historic District… Plywood may be approved “but only where edges are not visible.”

COMMENT: this is absurd. Contrary to this a variety of composite lumbers are routinely accepted by the HPC and used as beams, rafters and joists in additions, rehabilitation, and new construction in the historic district. This includes the full range of laminated lumbers that go by the generic terms structural composite or engineered lumber – oriented strand, parallel strand, laminated veneer, and laminated strand products. Oriented strand board (OSB) is the standard sheathing for external walls, roofs and floors. Structural insulated panels (SIPs) were approved and indeed featured as part of the Nexus Energy project with some 60 houses in the northwest corner of the historic district.

1. (cont) All visible wood surfaces must be painted or stained with a solid opaque stain that resembles a paint finish and conceals the wood grain.”

COMMENT: This is not historic preservation at all but nannying coercion under cover of preservation. Like all other old towns Frederick has historically had lots of roughsawn, unpainted lumber on its buildings and fences. Weathering or stains that do not conceal with wood grain have historically been common. What we have in this provision is an attempt to impose a sterile tidiness and uniformity more suited to Wall Disney’s artificial Celebration township in central Florida than to a real live historic city.

2. Visible pressure-treated wood only to be used in elements in ground contact. Not allowed in steps, porch posts, porch floors, trim or balustrades, or in gates and fences on the street.

QUESTION: Why? The Guidelines don’t give any rationale for this restriction which is anti-preservation. Preservation is enhanced by the insect-repelling and rot-resistance that pressure treatment imparts to lumber. Pressure treatment simply allows preservatives to be more efficiently applied throughout the inner cells of the lumber. Preservatives themselves are thoroughly historic, their use going back to ancient Greece with accounts of bridge wood soaked in olive oil and Roman times when it was standard practice to apply tar to exposed wood. Creosote was used as a wood preservative from the early 19th century. http://en.wikipedia.org/wiki/Wood_preservation



3. Siding and shingles.

“Siding, including shingles used for siding, on walls to be rehabilitated must be wood.”FCconstits

NOTE: This guideline requiring wood siding is flagrantly violated by the HPC which for several years has been approving fiber-cement siding, most commonly a product of James Hardie Industries plc’s JHlogoHardiePlank (trademark). Developed in Australia where it is called ‘fibro’ it has been taken a long way from being a brittle product of cement and sand with asbestos fibers. Using wood fibers it is now asbestos-free and safe and more resilient. It is now both cheaper and longer lived than wood. It is an excellent economical product which contributes to preservation. If the HPC were serious about the Guidelines as it claims it would correct its Guidelines to accept this synthetic wood product rather than disregard them.

And the Guidelines Introduction’s statement: “These guidelines are the basis of the review process and the foundation for decision-making by the Commission.” (bottom of p8) needs an addendum: “…except when the Commission decides to disregard them.”

The Introduction and Chapter 1 were covered previously in Part 1:


see official Guidelines here:



Peter Samuel 2014-07-19



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